Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT ruled that Assessing Officer (AO) did not exceed jurisdiction in conducting complete scrutiny without additional approval. Case involved three significant factors: non-submission of mandatory assets/liabilities schedule for high-income taxpayer, substantial lending operations disproportionate to reported income, and significant loan settlements requiring verification. These aspects inherently warranted comprehensive examination beyond limited scrutiny parameters. CIT(A)'s observation regarding procedural non-compliance with CBDT circular for conversion from limited to unlimited scrutiny was deemed erroneous, as initial selection parameters themselves justified complete scrutiny. Given the nature of financial transactions and reporting requirements, case was inherently qualified for comprehensive examination from inception. ITAT held AO's actions were within jurisdictional scope.
ITAT ruled that Assessing Officer (AO) did not exceed jurisdiction in conducting complete scrutiny without additional approval. Case involved three significant factors: non-submission of mandatory assets/liabilities schedule for high-income taxpayer, substantial lending operations disproportionate to reported income, and significant loan settlements requiring verification. These aspects inherently warranted comprehensive examination beyond limited scrutiny parameters. CIT(A)'s observation regarding procedural non-compliance with CBDT circular for conversion from limited to unlimited scrutiny was deemed erroneous, as initial selection parameters themselves justified complete scrutiny. Given the nature of financial transactions and reporting requirements, case was inherently qualified for comprehensive examination from inception. ITAT held AO's actions were within jurisdictional scope.
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